Responsible Investing Policy

Our firm was founded in the year 1919, with the aim to professionalize the practice of investment counsel. 1919 Investment Counsel (“1919”) deploys a team of highly-trained, experienced, and ethical advisors, subject to a rigorous standard of conduct. We put the client’s interests before our own, and pledge to provide bespoke advice for each client, whose needs are unique and cannot be met with an off-the-shelf solution. Our team constructs highly-customized portfolios that meet the specific mission and investment mandates of the endowments, foundations, corporations, pensions, families, and individuals we serve.

1919 maintains a Responsible Investing Committee, which oversees the firm’s responsible investment (“RI”) approach and activities.

RESPONSIBLE INVESTING

Informed by our rigorous, research-driven investment approach, 1919’s experience as a responsible investment manager spans approximately 50 years. 1919 combines prudent, active portfolio management and proprietary research into a client-specific customized portfolio solution. Clients may self-select to participate in RI services. We work closely with each RI client to understand their perspectives, goals, and the issues that matter most to them.

Our approach to RI is primarily comprised of two complementary elements.

A. Values-Based Investing

At 1919, we work closely with our clients to understand their perspectives, goals, and the social issues that engage them. Within the portfolio construction process, we strive to invest in companies in alignment with each client’s expressed values, and avoid those companies that are not.

Client-directed values-based guidelines are specific to each client, documented, and integrated in the investment process. Some components of client-directed guidelines may overlap with similar Environmental, Social, and Governance factors (described below). In the event of a conflict, client-directed values-based guidelines will be the determinant in security selection.

B. Investing for Impact

At the behest of our RI service clients, we seek to invest in companies that are working to generate a positive social or environmental impact related to certain themes. These themes are informed by the UN Sustainable Development Goals (SDGs), which aim to achieve a more sustainable and just world for existing and future generations. Periodically, the RI team affirms the specific themes and definitions based on client feedback as well as industry standards. Seeking investment opportunities, which are determined to have a favorable social or environmental impact is similar to incorporating a non-exclusionary or affirmative client-driven guideline.

1919 supports exercising shareholder rights. We actively participate in collaborative engagement networks, and targeted corporate engagement efforts aiming to encourage greater corporate disclosure around a company’s environmental, social, and governance activities, risks, and opportunities.

ENVIRONMENTAL, SOCIAL, AND GOVERNANCE

We consider Environmental, Social, and Governance (ESG) factors using two separate but related processes:

1. Client-driven portfolio guidelines: Some clients have directed 1919 to apply E, S, and/or G factors as guidelines under the RI platform. (See Responsible Investing section above.)

2. Research process: We welcome the growing acknowledgement in the broader investment community that some E, S, or G factors have the potential to influence investment decisions.

We adhere to an investment process that relies on proprietary, independent research from our analysts and the collective expertise of our dedicated RI team. Our RI investment process considers a number of financial and non-financial factors, including identified ESG factors. ESG factors may enhance our understanding of each company and the broader market. However, ESG factors may not be the primary consideration for all investment strategies and accounts.

Examples of ESG factors that we consider may include, but are not limited to:

• • Environmental: climate change and carbon emissions, air and water pollution, biodiversity, deforestation, energy efficiency, waste management, and water scarcity
  • Social: customer satisfaction, data protection and privacy, gender and diversity, employee engagement, community relations, human rights, and labor standards
  • Governance: board composition, audit committee structure, bribery and corruption, executive compensation, lobbying, political contributions, and whistleblower schemes

STEWARDSHIP

1919 actively votes proxies for each client account where we have been given authority to do so. In voting proxies, we are guided by general fiduciary principles. Votes for companies held in RI client portfolios are voted according to a socially responsible voting policy. Our proxy voting reflects the dual objectives of economic gain and expecting companies to conduct their businesses in a socially and environmentally responsible manner. Voting records are provided to clients upon request.

 

Approved by RI Committee: 02/17/2022

Approved by IPC: 02/24/2022